We at Spil Games BV (“Spil”, “we”, “us” or “our”) respect your privacy and recognise the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process your personal data.
The purpose of this privacy notice (“Privacy Notice”) is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you, “Personal Data”) when you play our games and visit the gaming websites that are part of our gaming platform. This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing.
In this Privacy Notice, we will give you general information about how we process your Personal Data. We will furthermore give you more detailed information on the processes within our Services.
GENERAL INFORMATION
In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you access or play a game from one of our Gaming Websites. For specific information with more details about our processing activities on the respective Gaming Website, please see the service specific information below.
Who is responsible for the processing of your Personal Data
Boeing Avenue 30, 1119 PE Schiphol-Rijk Netherlands is responsible ("the data controller") for the processing of your Personal Data.
You can reach our data protection officer under dpo@azerion.com.
What types of Personal Data do we process and how do we collect it?
When you access or play a game from one of our Gaming Websites, we collect, use, store and transfer different kinds of Personal Data. As a general principle, we do not collect and do not ask you to provide any "special categories of Personal Data", which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation.
The information we collect depends on which of our games or Gaming Websites you use and how you use them. We process the following types of your Personal Data:
Personal Data provided by you
You can visit and play our games without registering or logging into our websites. When you access or play a game from one of our Gaming Websites, you provide or be asked to give us certain information, including:
Data provided in relation to our customer service: When you contact support, we collect information about your request (subject and content of your request) and your contact details (e-mail address).
Game ratings: We collect rating information if you use the voting button on our Gaming Websites (like and dislike buttons).
Your account information: On our Gaming Websites, you have the option to sign up for an account. If you choose to create an account, we collect your log-in data (your email address, date of birth, name, surname and password). For some of our Gaming Websites, we use a single sign-on solution called Azerion Connect and when you create an account on those Gaming Websites, you create an Azerion Connect account.
Personal Data we receive or generate from your use of our Services
When you access our Gaming Websites or play a game from our Gaming Websites, we also process device-related information and information about how you interact with our games or Gaming Websites, including:
Technical information: We collect information about your device/device settings and may combine this information across different devices you use for the purposes described below. The information we obtain from these devices includes the type of your device, browser information online identifiers (your IP address), device IDs, game/site ID, geolocation data (based on your IP address), and other technical information.
Cookie data: As further described in our Cookie Notice ("Cookie Notice"), we use cookies and similar technology such as pixels or local storage and allow third parties to use cookies and similar technology for the purposes described below. The exact process of placing cookies, and the scope of the data that may subsequently be processed is set out in our Cookie Notice.
Your usage: We collect information about how you use our Gaming Websites or play the games available on our Gaming Websites. This information includes your preferences, such as your interests in certain categories of Games, the actions you take, the time and duration of your activity. Furthermore, we collect information about the websites that led you to our Gaming
Personal Data we collect from other third parties
In certain scenarios, we will also obtain your Personal Data from third parties, in strict compliance with applicable data protection laws and regulations. Your Personal Data may be provided by the following third parties:
Payment Providers: If you make in-game purchases, the transaction will be processed by a third-party payment provider and will be subject to third-party payment providers' privacy policies. For these transactions, we do not receive any specific financial information (such as the payment method or your credit card information), but may receive information which is related to your transaction, for example, the item you bought, payment status and payment date.
Social Networks and connected third-party platforms: If you access our Gaming Websites or play a game from our Gaming Websites by logging-in via a third-party platform (Facebook, Google or Apple), and you have created an account on the third-party platform, the authentication token is shared with us.
User acquisition companies: If you click on our advertisements shown to you in a third-party network, we will receive campaign information (the campaign ID, clicks on our ads, creative views), information about the which game or Gaming Website you visited, your country and language, and technical identifiers from our user acquisition partners.
We also receive information about your approximate geolocation (the country you are located in) from third parties (e.g. Google). We use this information to comply with our legal obligations applying to the processing of your Personal Data, customize certain services to your location, and for fraud or abuse prevention purposes.
To learn more about which data is processed on the respective Gaming Website from a specific Gaming Website, please see the section with service specific information below.
For What Purpose do we process your data?
Depending on which Gaming Website you are using and which privacy settings you have selected, we may process your Personal Data for the following purposes:
Provision and improvement of our games and services
to allow you to play our games, including third-party games available on our Gaming Websites
to create and manage your account
to communicate with you in context of account activation, password management
to simplify the registration process
to provide technical support and respond to your requests
to identify and correct any bugs/errors
to indicate the popularity of our games
to assess the quality of our services
to understand and improve your online experience
to aggregate financial reports to pay our business partners
Personalization of your game experience
to remember your preferred game settings
to show you your preferred games
to recommend games you may like based on your preferences
to personalize advertising for you
to remember you next time you visit one of our Gaming Websites
Marketing and analytics
to deliver (targeted and non-targeted) advertising in our games or on our Gaming Websites
to measure the effectiveness of advertising
to send you marketing communications, informing your about new content and in-game offers
to understand usage of our Services across all our group companies to support strategy and growth
Prevention of fraud and illegal activity
to investigate fraud and illegal behaviour on our Gaming Website and reporting it to relevant authorities
to enforce our policies and terms of use
Compliance with our legal or regulatory obligations
to determine the legal requirements for processing of your Personal Data (based on your location and your age)
to obtain a valid (parental) consent, if necessary
to respond to your requests related to your data subject rights to comply with our legal obligations (e.g. tax and accounting obligations)
to inform you about any changes to this Privacy Notice
Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data per Gaming Website.
Do we engage in profiling activities?
If you consent to this via the cookie consent pop-up, We use tracking mechanisms to track your Personal Data for profiling purposes. This allows us to serve relevant content to you and adjust our services and ads to your interests. You have the right to object to this type of processing. You can also go to your privacy settings to review and amend your privacy choices related to this type of processing at any time.
On Which legal basis do we process your Personal Data?
We process your Personal Data for the purposes described in this Privacy Notice, based on the following legal grounds:
Your consent: We process your Personal Data if you have provided your consent for a specific purpose. For example, when you enter our Gaming Website for the first time, we ask for your consent for the data processing in context of personalized advertising, analytics, profiling, social media and games from external publishers. We also show you just-in-time contextual notifications and consent pop-ups to obtain your consent for further processing activities. You have the right to withdraw your consent at any time, for example by changing your privacy settings. Please note that this will not affect any processing carried out before you withdraw your consent.
Performance of a contract: We process your Personal Data for the performance of a contract to which you are a party , for example, where it is necessary for the creation and administration of your account, to support the operation of our games or facilitate the delivery of requested services.
Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations, for example, in order to verify your age,for tax and accounting purposes or legal disputes as well as any requests or claims from legal authorities
Legitimate interests: We also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we process your Personal Data for improvement of the service provided to you or to provide you with a better user experience or we transfer your personal data across all our group companies for administrative transfers as well as to determine the size of the user base of our Services.
Please see for additional information the section with service specific information below.
With whom do we share your Personal Data?
We will not disclose your Personal Data to any party who is not authorised to process them. To manage our services, we will share your Personal Data internally with members of our responsible departments and technical support involved in the gaming process and in each case only if access to your Personal Data is necessary for the performance of their roles.
Moreover, and only when necessary to fulfil the purposes mentioned above, we disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our games or Gaming Websites:
Group companies: We share your personal data with our group companies which are responsible for internal analytics for the purposes of cross-product audience measurement. Where we share your personal data with our group company, we have appropriate agreements (an intra-company data sharing agreement) in place to ensure that your personal data is processed in compliance.
External service providers: We share your Personal Data with external service providers who perform services on our behalf, like customer support service, IT services, hosting and content delivery services, web/social analytics services, data management services, social media sharing service, video hosting service, and user notification services. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.
Payment providers: If you make in-game purchases, the transaction will be processed by a third-party payment provider and will be subject to the third-party payment provider's privacy policy.
Third-party game Distributors: On our Gaming Websites, we offer games from third-party game distributors. By playing a third-party game, your Personal Data will be processed by the third-party game distributors (directly or through the use of cookies or similar technology). Please note that by choosing a third-party game, you will be able to play the game in the third-party game developer's environment over which we have no control. We only receive anonymized statistics and revenue reports from third-party game distributors. We therefore advise you to check the privacy policies of any such game distributor before starting the game. Furthermore, you can find the third parties your Personal Data may be processed by playing our games or Gaming Websites in the following link: 3rd Party list.
advertising companies: With your consent, we share your Personal Data with third-party advertising companies or allow third-party advertising companies to collect your Personal Data when you access or play a game from our Gaming Website. If you choose not to receive personalised ads at all, we will still show you ads, but they may not reflect your interests as those ads will be content specific and not user specific. Please note that by clicking on a third-party advertisement, you will be redirected to the third-party advertiser's environment over which we have no control.
Law enforcement, government authorities or courts: We disclose your Personal Data in response to lawful requests to public authorities, including law enforcement, government authorities, or courts. We may also disclose your Personal Data to legal authorities where we believe such disclosure is necessary for prevention of a crime, facilitation of an investigation related to public safety, protect the security or integrity of our Service, or enable us to take precautions against liability or to protect our rights.
Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).
Please see the section with service specific information below for more information about the third parties we may share your data with.
